Turkish Trade Monitor – July 2026
July 2026 brought significant regulatory changes in Türkiye, particularly across healthcare products, data protection, marketing practices and civil litigation. New licensing regimes were introduced for aromatherapeutic products and medicinal herbal teas, while the rules governing traditional herbal medicinal products and foods for special medical purposes were revised.
At the same time, the Turkish Data Protection Authority intensified its focus on unlawful access to personal data and the use of third-party contact information for marketing. Law No. 7589 also introduced major procedural reforms affecting civil litigation, statutory interest, enforcement proceedings and the conduct of hearings.
New Licensing Regime for Aromatherapeutic Products
Türkiye has introduced a dedicated regulatory framework for aromatherapeutic products marketed with claims relating to the protection of human health, treatment of disease or support of medical treatment.
The Regulation covers essential oils, fixed oils, hydrosols and mixtures intended for use through aromatherapy methods. Products intended for internal use are excluded, as are products already classified as foods, cosmetics, medical devices or traditional herbal medicinal products.
Aromatherapeutic products may not be placed on the market without authorization or used by pharmacies in magistral preparations unless duly authorized. Applications will generally be submitted electronically and must be supported by extensive documentation covering composition, intended use, safety, quality, pharmacopoeial or monograph compliance, manufacturing authorization, stability, vigilance, allergy testing, environmental risks and packaging.
Foreign manufacturers planning to enter the Turkish market should therefore review not only the composition of their products but also intended claims, labels, promotional materials and distribution model before determining the applicable regulatory route.
Traditional Herbal Medicinal Products: Scope and Licensing Rules Revised
The Regulation on the Licensing of Traditional Herbal Medicinal Products has been amended to create a clearer distinction between traditional herbal medicinal products, medicinal herbal teas and aromatherapeutic products.
Medicinal herbal teas and aromatherapeutic products are now expressly separated from the traditional herbal medicinal product regime and regulated under their respective frameworks. Several key definitions, including traditional herbal medicinal product, active substance, benefit-risk balance, well-established use and applications involving endemic plants, have also been revised or expanded.
The amendments also strengthen the evidentiary requirements for demonstrating traditional use. Applicants must support such use with verifiable bibliographic documentation recognized by the Turkish Medicines and Medical Devices Agency as scientifically valid or with scientific evidence establishing well-established use.
Foreign manufacturers should classify each SKU individually and review existing product dossiers to determine whether additional evidence of traditional or well-established use will be required in Türkiye.
Foods for Special Medical Purposes: New Pesticide and Licensing Rules
The licensing framework for foods for special medical purposes has been amended in relation to pesticide residue limits and regulatory assessment procedures.
The previous reference to the total amount of pesticide residue limits has been replaced with an approach based on the residue limit applicable to each individual pesticide. This means that compliance will be assessed separately for each pesticide rather than against an aggregate threshold.
The Turkish Medicines and Medical Devices Agency has also been expressly authorized to establish commissions or obtain opinions from scientific advisory commissions where required during the evaluation of these products.
Importantly, the transitional deadline has been extended from 1 July 2026 to 1 July 2027. Products for which a licensing application is submitted by this date may continue to be placed on the market under their existing permissions until the licensing process is completed. Existing permissions for products without a timely licensing application will become invalid.
Companies should use this period to review pesticide specifications, technical dossiers and their Turkish licensing strategy. Products currently marketed under existing permissions should be identified early to ensure that applications are filed before the 1 July 2027 deadline.
Medicinal Herbal Teas Become Subject to a Dedicated Licensing Regime
Türkiye has introduced a new Regulation specifically governing medicinal herbal teas prepared from pharmacopoeial-quality medicinal plants and herbal drugs with health-protective or therapeutic effects.
The Regulation covers industrially manufactured and magistrally prepared medicinal herbal teas consisting of a single herbal drug or combinations of several herbal drugs. These products will be sold exclusively through pharmacies. Ordinary herbal and fruit teas marketed under food legislation remain outside the scope.
Medicinal herbal teas may not be placed on the market without authorization. Applications must generally be submitted electronically and supported by information concerning quality, safety, pharmacopoeial compliance, intended use, shelf life, storage conditions, packaging, instructions for use, manufacturing facilities, analytical reports, stability, vigilance and allergy testing, as well as clinical or preclinical data where necessary.
Additional requirements apply to herbal drugs derived from endemic plants or plants specific to Türkiye, including taxonomic records, evidence of endemic status, sustainable sourcing plans and, where applicable, CITES compliance documentation.
Foreign tea and botanical product manufacturers should therefore review their labels and marketing claims before entering Türkiye. Products positioned with therapeutic or health-protective claims may require authorization and pharmacy-only distribution rather than ordinary food registration.
KVKK Principle Decision Targets Unlawful Contact with Accident Victims
The Turkish Personal Data Protection Board issued a principle decision following numerous complaints concerning accident victims being contacted without request or consent by claims consultancy companies, insurance-related intermediaries, lawyers and individuals presenting themselves as lawyers.
The Board emphasized that personal data obtained following traffic accidents, workplace accidents and similar events may only be processed within the legal purposes for which the information was originally obtained. Unlawfully accessing, transferring or using such information to solicit accident victims may trigger administrative sanctions under the Personal Data Protection Law and may also constitute a criminal offence under the Turkish Criminal Code.
Organizations holding accident-related data are expected to implement measures including access restrictions based on the minimum-authorization principle, role-based access controls, logging and monitoring systems, as well as employee training.
Companies should review who can access this information internally and whether data is transferred to external service providers. Accident-related personal data cannot be repurposed as a sales or client-acquisition database merely because an organization has technically gained access to it.
Third-Party Referrals Do Not Create a Legal Basis for Marketing
The Turkish Personal Data Protection Authority issued a public announcement addressing the use of phone numbers, email addresses and other contact details obtained from customers or third parties through referral programs, recommendations, brand ambassador schemes or similar arrangements.
The Authority clarified that receiving personal data from a third party does not, by itself, provide a lawful basis for using that information for advertising or marketing. Where contact details have not been obtained directly from the individual and will be used to contact them, the individual must generally be informed no later than the first communication.
The Authority also rejected the use of implied behaviour as consent. Continuing to listen to a campaign presentation, asking questions during a call, failing to terminate the conversation or failing to respond to an SMS does not, by itself, constitute valid explicit consent. Where processing relies on consent, the privacy notice and consent process must be conducted separately.
Companies using referral campaigns, call centers or third-party lead databases should review how contact details are obtained, when privacy information is provided and how valid marketing consent is documented. Existing CRM databases containing externally sourced leads should also be audited.
Law No. 7589 Introduces Major Changes to Civil Litigation and Statutory Interest
Law No. 7589, commonly referred to as part of Türkiye's judicial reform package, introduces significant changes across civil procedure, enforcement, administrative justice, statutory interest and criminal procedure.
One of the most significant changes for commercial litigation is the repeal of Article 107 of the Code of Civil Procedure, which previously governed unquantified debt claims. Instead, the partial claim mechanism has been expanded. Where only part of a receivable is initially claimed, the claimant may increase the amount once, until the end of the evidentiary phase, without being subject to the prohibition against expansion of claims. Limitation periods for the increased portion will be deemed interrupted as of the original filing date. Claims filed under the former Article 107 before its repeal will continue to be governed by the previous rules.
The Law also provides that the interval between hearings in civil proceedings may not, as a rule, exceed three months. Longer intervals remain possible where justified by circumstances such as extended expert examinations or proceedings conducted through letters rogatory.
Another major financial change concerns statutory interest. Rather than operating under a fixed-rate structure, the statutory interest mechanism is now linked to 80% of the rediscount rate applied by the Central Bank of the Republic of Türkiye to short-term credit transactions at the end of the preceding year. Where the rate applicable on 30 June differs by at least five percentage points, the updated rate will apply during the second half of the year.
The reform further addresses electronic transmission of notarized documents to judicial authorities, electronic sales involving assets of persons under guardianship, rules governing participation in hearings through audio and video systems, consolidation and separation of proceedings, appeal thresholds and administrative proceedings.
Most provisions entered into force upon publication on 31 July 2026, while certain provisions relating to electronic procedures and remote participation enter into force three months after publication.
The new three-month hearing rule is also intended to reduce lengthy gaps between hearings, although complex cases involving expert evidence may still take longer. For companies carrying significant litigation exposure, the new floating statutory-interest mechanism is equally important because prolonged proceedings may create higher and more variable interest liabilities than under the previous fixed-rate model.